ABA: Request for Employee Benefit Q&As for Government Agencies

The following is from a letter we received this morning from Phyllis C. Borzi, Chair of the American Bar Association Joint ommittee on Employee Benefits. It is being posted for the benefit of those who would have an interest in responding:

Dear Employee Benefits Practitioner:

Every year, the Joint Committee on Employee Benefits (JCEB) presents questions from the members of the employee benefits committees of the six Sections of the ABA participating in the JCEB to various federal agencies in Washington, D.C. The agency meetings are held immediately before the May meeting of the Tax Section. This year the JCEB will be meeting with the IRS, DOL, SEC, PBGC, EEOC, HHS and CMS. This is your opportunity to ask technical questions of the staffs of the various agencies. The results of these meetings will be summarized in a written report which will be published on the JCEB website www.abanet.org/jceb/.

In order to provide the agencies with sufficient notice to answer the questions, the questions must be submitted to designated individuals by March 5, 2009. Each question to the IRS and DOL must contain your proposed answer and an analysis demonstrating why you think the answer is correct. Questions for the IRS and DOL which do not contain an analysis and proposed answer will not be submitted. Including the proposed answer and analysis is also recommended for the other agencies. For all agencies, questions previously submitted should not be resubmitted this year unless there has been an intervening event and no questions should be submitted that involve pending controversies before the agency or a controversy in litigation. For all agencies, please include a reference and citation to any case decision or on-going litigation that involves the question that has been posed.

Please address your questions and proposed answers to the following individuals:

The Agency Q & As have always been one of our most popular ABA activities. The success of this endeavor is directly dependent upon the number and quality of the questions which you provide. Thus, your questions are extremely important to the success of these meetings. The JCEB thanks you, in advance, for your active participation in this event.